IBM CORPORATION,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, INTERNATIONAL TAXATION-CIRCLE-1(2) , BANGALORE

In the result, all the appeals of the assessees are allowed

Bench: Shri Chandra Poojari & Smt. Beena Pillai

penalty on the offered pursuant to a survey proceeding assessee. under section 133A of the Act. No - The CIT(A) has rejected IBM’s bonafide explanations were provided reference to the Punjab and Haryana under Explanation 1 of section 271(1)(c) HC’s ruling in CIT v. Rajiv Garg of the Act in respect of the income being

IBM CORPORATION,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, INTERNATIONAL TAXATION, CIRCLE-1(2)(1) , BANGALORE

In the result, all the appeals of the assessees are allowed

Bench: Shri Chandra Poojari & Smt. Beena Pillai

penalty on the offered pursuant to a survey proceeding assessee. under section 133A of the Act. No - The CIT(A) has rejected IBM’s bonafide explanations were provided reference to the Punjab and Haryana under Explanation 1 of section 271(1)(c) HC’s ruling in CIT v. Rajiv Garg of the Act in respect of the income being

IBM ISRAEL LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX , INTERNATIONAL TAXATION-CIRCLE-1(2) , BANGALORE

In the result, all the appeals of the assessees are allowed

Bench: Shri Chandra Poojari & Smt. Beena Pillai

penalty on the offered pursuant to a survey proceeding assessee. under section 133A of the Act. No - The CIT(A) has rejected IBM’s bonafide explanations were provided reference to the Punjab and Haryana under Explanation 1 of section 271(1)(c) HC’s ruling in CIT v. Rajiv Garg of the Act in respect of the income being

DCIT-CIRCLE-1(1), HUBLI, C.R. BUILDING , NAVANAGAR HUBLI vs. SHRI CHANDRASHEKHAR KOMMI, HUBLI

In the result, the appeal of the revenue is dismissed

Bench: Shri Chandra Poojari & Smt. Madhumita Royassessment Year: 2015-16

survey u/s 133A and furnishing inaccurate particulars of work expenses.” 2.1 Such initiation of penalty proceedings was culminated into an order levying penalty to the tune of Rs.59,22,201/- u/s 271

IBM DEUTSCHLAND GMBH,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, INTERNATIONAL TAXATION, CIRCLE-1(2)(1), BANGALORE

In the result, all the appeals of the assessees are allowed

survey proceeding\nunder section 133A of the Act. No\nbonafide explanations were provided\nunder Explanation 1 of section 271(1)(c)\nof the Act in respect of the income being\nsurrendered. The only argument made by\nthe Assessee was that it voluntarily\noffered receipts to tax and therefore,\npenalty cannot be levied.\n\nPage

IBM CANADA LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, INTERNATIONAL TAXATION, CIRCLE-1(2), BANGALORE

In the result, all the appeals of the assessees are allowed

u/s\n139) and thereby contending that the\nAssessee had not disclosed all the facts\nMAK Data (supra) ruling is in the context\nof a case where income was voluntarily\noffered pursuant to a survey proceeding\nunder section 133A of the Act. No\nbonafide explanations were provided\nunder Explanation 1 of section 271(1)(c)\nof the Act in respect

IBM AUSTRALIA LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, INTERNATIONAL TAXATION-CIRCLE-1(2), BANGALORE

In the result, all the appeals of the assessees are allowed

survey proceeding\nunder section 133A of the Act. No\nbonafide explanations were provided\nunder Explanation 1 of section 271(1)(c)\nof the Act in respect of the income being\nsurrendered. The only argument made by\nthe Assessee was that it voluntarily\noffered receipts to tax and therefore,\npenalty cannot be levied.\n\nPage

COMPAGNIE IBM FRANCE,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, INTERNATIONAL TAXATION-CIRCLE-1(2), BANGALORE

In the result, all the appeals of the assessees are allowed

survey proceeding\nunder section 133A of the Act. No\nbonafide explanations were provided\nunder Explanation 1 of section 271(1)(c)\nof the Act in respect of the income being\nsurrendered. The only argument made by\nthe Assessee was that it voluntarily\noffered receipts to tax and therefore,\npenalty cannot be levied.\nPage 28 of 56\nIT(IT)A Nos.487

IBM CANADA LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, INTERNATIONAL TAXATION, CIRCLE-1(2) , BANGALORE

The appeals of the assessees are allowed

survey proceeding\nunder section 133A of the Act. No\nbonafide explanations were provided\nunder Explanation 1 of section 271(1)(c)\nof the Act in respect of the income being\nsurrendered. The only argument made by\nthe Assessee was that it voluntarily\noffered receipts to tax and therefore,\npenalty cannot be levied.\nPage 28 of 56\nIT(IT)A Nos.487

IBM AUSTRALIA LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, INTERNATIONAL TAXATION-CIRCLE-1(2) , BANGALORE

In the result, all the appeals of the assessees are allowed

survey proceeding\nunder section 133A of the Act. No\nbonafide explanations were provided\nunder Explanation 1 of section 271(1)(c)\nof the Act in respect of the income being\nsurrendered. The only argument made by\nthe Assessee was that it voluntarily\noffered receipts to tax and therefore,\npenalty cannot be levied.\nPage 28 of 56\nIT(IT)A Nos.487

M/S. YASHASWI FISH MEAL AND OIL COMPANY,UDUPI vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1, MANGALORE

In the result, all the appeals of the assessee are partly allowed

Bench: Shri Chandra Poojari & Smt. Beena Pillai

survey and the undisclosed income of Rs. 5,50,00,000 admitted in the statement is assessed as the income of the appellant and added to the income under the head "Income from Business". 7.2 The ld. D.R. submitted that the AO, in the aforesaid order, relevant portion of which has been reproduced above given sufficient reasons backed by judicial

M/S. YASHASWI FISH MEAL AND OIL COMPANY,UDUPI vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1, MANGALORE

In the result, all the appeals of the assessee are partly allowed

Bench: Shri Chandra Poojari & Smt. Beena Pillai

survey and the undisclosed income of Rs. 5,50,00,000 admitted in the statement is assessed as the income of the appellant and added to the income under the head "Income from Business". 7.2 The ld. D.R. submitted that the AO, in the aforesaid order, relevant portion of which has been reproduced above given sufficient reasons backed by judicial

M/S. YASHASWI FISH MEAL AND OIL COMPANY,UDUPI vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1, MANGALORE

In the result, all the appeals of the assessee are partly allowed

Bench: Shri Chandra Poojari & Smt. Beena Pillai

survey and the undisclosed income of Rs. 5,50,00,000 admitted in the statement is assessed as the income of the appellant and added to the income under the head "Income from Business". 7.2 The ld. D.R. submitted that the AO, in the aforesaid order, relevant portion of which has been reproduced above given sufficient reasons backed by judicial

M/S. YASHASWI FISH MEAL AND OIL COMPANY,UDUPI vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1, MANGALORE

In the result, all the appeals of the assessee are partly allowed

Bench: Shri Chandra Poojari & Smt. Beena Pillai

survey and the undisclosed income of Rs. 5,50,00,000 admitted in the statement is assessed as the income of the appellant and added to the income under the head "Income from Business". 7.2 The ld. D.R. submitted that the AO, in the aforesaid order, relevant portion of which has been reproduced above given sufficient reasons backed by judicial

M/S. YASHASWI FISH MEAL AND OIL COMPANY,UDUPI vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1, MANGALORE

In the result, all the appeals of the assessee are partly allowed

Bench: Shri Chandra Poojari & Smt. Beena Pillai

survey and the undisclosed income of Rs. 5,50,00,000 admitted in the statement is assessed as the income of the appellant and added to the income under the head "Income from Business". 7.2 The ld. D.R. submitted that the AO, in the aforesaid order, relevant portion of which has been reproduced above given sufficient reasons backed by judicial

IBM ISRAEL LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX , INTERNATIONAL TAXATION-CIRCLE-1(2), BANGALORE

The appeals of the assessees are allowed

survey proceeding\nunder section 133A of the Act. No\nbonafide explanations were provided\nunder Explanation 1 of section 271(1)(c)\nof the Act in respect of the income being\nsurrendered. The only argument made by\nthe Assessee was that it voluntarily\noffered receipts to tax and therefore,\npenalty cannot be levied.\nPage 28 of 56\nIT(IT)A Nos.487

IBM JAPAN LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX , INTERNATIONAL TAXATION-CIRCLE-1(2) , BANGALORE

In the result, all the appeals of the assessees are allowed

survey proceeding\nunder section 133A of the Act. No\nbonafide explanations were provided\nunder Explanation 1 of section 271(1)(c)\nof the Act in respect of the income being\nsurrendered. The only argument made by\nthe Assessee was that it voluntarily\noffered receipts to tax and therefore,\npenalty cannot be levied.\n\nPage

IBM UNITED KINGDOM LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX , INTERNATIONAL TAXATION-CIRCLE-1(2), BANGALORE

In the result, all the appeals of the assessees are allowed

survey proceeding\nunder section 133A of the Act. No\nbonafide explanations were provided\nunder Explanation 1 of section 271(1)(c)\nof the Act in respect of the income being\nsurrendered. The only argument made by\nthe Assessee was that it voluntarily\noffered receipts to tax and therefore,\npenalty cannot be levied.\nPage 28 of 56\nIT(IT)A Nos.487